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Re: Hvp123 post# 741661

Monday, 12/05/2022 5:07:49 PM

Monday, December 05, 2022 5:07:49 PM

Post# of 869656
Prayer For Relief in Bhatti case

2. Entering an injunction that restores plaintiffs to the position they would have been in were it not for the unconstitutional removal restriction. At a minimum, such an
injunction should direct Defendants to either (a) reduce the liquidation preference on Treasury's senior preferred stock to zero and end further increases to the liquidation preference except as necessary to offset any further draws on Treasury's funding commitment; or (b) convert Treasury's senior preferred stock to common stock.
3. Entering an injunction directing Defendants to provide any other credits or
adjustments that are necessary to put plaintiffs in the position they would have been in were it not for the unconstitutional removal restriction.
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